Welcome to the FENG Privacy Policy (“Policy”)! This explains how we collect, store, protect, and share your information, and with whom we share it. We suggest you read this along with our Terms and Conditions.

Whilst you’re enjoying the FENG mobile application (“App”) or using our digital products and services (such as our surveys or competitions) (together, referred to in this Privacy Policy as our “Sites”), we collect some information about you. In addition, you may choose to use the App or Sites to share information with other users, including your friends and contacts (“Users”). We may also need to share your information sometimes.

The App and Sites are global, and your information will be sent to and used in the United Kingdom and United States regardless of the country you reside in. This Policy explains how we protect your personal data when we transfer it overseas, so please read it very carefully!

The App is operated by “FENG” (also referred to in this policy as “we” or “us”) which includes FENG, which is the controller of personal information collected and processed through the FENG App.

App For Life Limited has designated a Data Protection Officer and they can be reached by emailing hello@feng-app.io

or by post at the following address: 85, Great Portland Street, London, W1W 7LT, United Kingdom.

Unless otherwise stated in this privacy policy or in our Cookies & Tracking Policy, the data controller of your personal data is FENG, 85, Great Portland Street, London, W1W 7LT, United Kingdom (hereafter “FENG”, “us”, “our”, “we”).

If you have any questions or suggestions about how we use your personal data, please contact us or our data protection officer. Our contact details are as follows:

FENG, 85, Great Portland Street, London, W1W 7LT, United Kingdom, hello@feng-app.io (email)

You can reach our data protection officer at: DPO, hello@feng-app.io (email)

Registration Information

When you download the App and create an account (“Account”), we may collect certain information (“Registration Information”) about you, such as the following:

• Name
• Username
• Email address
• Mobile number
• Gender identity
• Date of birth
• Sexual preference
• Photographs
• Location
• Login information for social media accounts that you connect to your FENG Account (this could include, for example, your Facebook and Instagram accounts). For more information about this, see “Linking other Accounts to FENG” in section 7 below.

You will also be required to create a password when you register an Account with FENG. Once you register, you will be able to review and change this information at any time just by logging in to FENG (other than your date of birth and location (which, if you have given FENG access to your location in your device settings, is automatically updated based on the location of your device)). It is your responsibility to make sure that your account details are kept up to date. If your phone number changes, please ensure that you update this in your account.

The information we collect helps to enhance the App and verify our Users (robots are not welcome!). Registration Information including but not limited to, your sexual preference, name and username may be visible to other Users who view your profile page.

Profile Information

We both encourage and recommend you (and all our members) to think carefully about the information you disclose about yourself. We also do not recommend that you put URLS, email addresses, instant messaging details, full names or addresses, phone number, credit card details, national identity numbers, drivers’ licence details and other sensitive information which is open to misuse and abuse on your profile.

When you post personal information or use the messaging function to communicate with other Users, the amount of personal information you share is at your own risk. Please see Section 4 below for more information on who can access what you post on FENG.

Profile Verification Information

For safety and security and to ensure you have the best possible user experience (!), we require Users to verify their accounts and might ask for your phone number and, in some instances, we might also ask that you carry out *photo verification as we want to make sure you are not a robot! Likewise, we also want to avoid fake FENG accounts being created which can be used for cybercrime and malicious activities– they threaten the FENG network and ruin things for everyone! This verification might be required by us for the prevention of fraud. You can also verify your photo on a voluntary basis (and will then have a verified profile tag on your account).

*Photo verification is when a user is requested by FENG to upload a photo in real-time ie a selfie taken at that exact moment. Once the user has uploaded their photo, our admin will check the real time photo against their profile photos to see if it matches to then be able to approve and accept the user’s profile on the FENG platform. If the uploaded photo is of bad quality and not up to our accepted standard, it will be rejected and a user will have to add it again, going through the same process until the real-time photo is approved and the user is accepted onto the FENG platform.

Our main goal is to ensure your experience on FENG is an enjoyable one and you don’t end up with a fashion faux pas! In order to deliver an enjoyable experience to you, we may use your Registration and other information to:

• offer you our features and services;
• contact you with information about the App (e.g., such as new features and updates);
• personalize the App/website and the content we deliver to you;
• conduct research and analytics about how you use and interact with the App/website;
• troubleshoot problems, resolve disputes and to enforce our Terms & Conditions;
• protect our legal rights, investigate fraud and to enforce our Terms & Conditions.
• to send you information about offers and promotions we have available – if you’ve signed up for our marketing emails when you provided your email address, or otherwise told us you’re happy to receive these (you can withdraw this consent at any time via Settings in the App or by using the opt-out mechanisms and links provided in each message); and
• protect our Users and third parties from harm.

Purchases Information

If you purchase any of our premium services (subscription), we will process your payment information and this will be retained securely for the prevention of fraud, and for tax/audit purposes.

As part of its anti-fraud procedures, FENG uses automated decisions to prevent fraudulent payment transactions being processed. We do this by our systems checking payment transactions for behaviour that indicates breaches of our Terms and Conditions. If a transaction meets certain criteria that demonstrate that the Terms and Conditions have likely been breached and the transaction is in turn likely to be fraudulent, the relevant transaction could automatically be blocked. When a transaction is blocked, the user will be notified that their transaction cannot be processed. Affected Users can contact FENG to contest the decision.

Please note that if your account is blocked for any reason this is being done as part of our anti-fraud and anti-spam procedures.

Geolocation Information

When you use your mobile, if you have given FENG access to your location in your device settings, we will collect information such as WiFi access points and other location information about your longitude and latitude. We may also save your device’s coordinates to offer certain features to you. The use of this information helps us identify your physical location which we use to personalize the App and make your user experience easier for you to interact with other Users, by enabling the general locality information to be displayed showing you the profiles of other Users who are near you as well as those nearby users seeing your profile.

If you have given FENG access to your location, but wish to turn this off, you can do so by the following methods:

1. Android — settings, location, FENG, permissions, location
2. iPhone app — settings, privacy, location services, FENG

Device Information

We may collect information about your device when you use the App including the unique device identifier, operating system, MAC address and device model, for a number of reasons, as set out in this policy.

Links

FENG may keep track of how you interact with links available on FENG inclusive of third party services by redirecting clicks or through other means. We may share aggregate click statistics such as how many times a particular link was clicked on.

FENG Surveys, Success Stories and other Contributions

Every now and again, we run surveys for research purposes. We may contact you to ask if you would like to take part. Furthermore, we might contact you to find out if you would be willing to provide feedback, or take part in marketing campaigns (such as if you let us know that you have found a match on the App, we might contact you to ask if you would like to feature in a FENG advert) or write a testimonial. Marketing campaigns and surveys are optional and more details will be provided at the point of contact. If you do not want to be contacted to be part of a marketing campaign or take part in a survey, then please contact our Customer Support Team at Hello@feng-app.io

When you Contact Customer Support

By contacting our Customer Support team via Hello@feng-app.io, we will receive your email address, and may track your IP address, as well as using the information you send to us to help resolve your query. We will also retain records of our communications with you, including any complaints that we receive from you about other Users (and from other Users about you) after deletion of your account.

Cookies and similar technologies

We may collect personal data from you automatically when you visit our website or when you use our App, by using cookies or similar technologies. A cookie is a small file that can be placed on your device or browser that allows us to recognize and remember you.

If you would like to find out more about cookies, including how we use them and what choices are available to you, please refer to our Cookie Policy.

Moderation Practices

We use a team of moderators to monitor and combination of moderation systems to review accounts (including photos and any other information uploaded onto user profiles) and messages for content that indicates breaches of our Terms and Conditions of Use. If a message or account meets certain criteria that demonstrate that the Terms and Conditions of Use may have been breached, the relevant account will be subject to a warning and the user’s access restricted and/or blocked. Affected Users can contact FENG to contest the decision.

If you post anything that is inconsistent with our Terms and Conditions, we reserve the right to restrict access to your Account or terminate your Account.

Lawful Basis

Under EU and UK data protection laws, we are required to tell you about our lawful basis for using your data and we have set this out in the table below. Where the legal basis is legitimate interests, you have a right to object to our use of your data. Where the legal basis is consent, you can withdraw consent at any time.

We explain in the relevant sections in this Policy how you can or opt-out of certain data uses or withdraw consent (where applicable).

Aggregated Information – We may share aggregated information with third parties that includes your personal data (but which does not directly identify you) together with other information, including log data for demographic profiling and industry analysis.

3. DISCLOSURE OF INFORMATION

Our policy is to not disclose your personal date or Registration Information, except in the limited circumstances described here:

We think our Users are the best, and most fashionable in the world and we want you to share how fashionable and in vogue you are with the world, so we have built certain features to enable this. Our App is designed to make it easier for you to connect with other Users with a mutual love of fashion and to interact with them.

Whilst using the FENG App, you should assume that anything you submit or post on the App may be both accessible and publicly viewable, both by Users and non-users of the FENG App. We want our Users to be careful about posting information that may eventually be made public.

We ask you to please be very careful over what you post in regards to sensitive details about yourself on your profile, such as health details and religious denomination. You may wish to choose to add sensitive personal information when you add certain FENG tags to your profile, such as your religion and life choices. There is no requirement to add this information and it is done on a voluntary basis. Please be aware that photographs that you post on FENG may reveal information about yourself too. Where you do choose to upload and reveal sensitive personal information, including through adding tags to your profile, you are consenting explicitly to our processing of this sensitive information and making it public to other Users.

Your FENG profile and other information you make available via the App, including certain information added to your profile through third party accounts (such as Facebook, Instagram, Apple Music or Spotify – see section 7 of this Privacy Policy for more information about this) may be shared and viewed by Users with individuals who may/ may not be users of the FENG App. For example, a User may take a screenshot of your profile picture and share it, regardless of whether such friend(s) is also a User of the FENG App and recommend you as a match to his or her Instagram friend(s) regardless of whether such friend(s) is also a User of the FENG App.

If you log in to or access the FENG App through your Facebook, Google, or Apple account or another third-party account on a shared device, remember to log out of the FENG App and the relevant third-party account when you leave the device in order to prevent other users from accessing your FENG account.

MORE INFORMATION ABOUT DISCLOSURES

Sharing your personal data with Service Providers

To perform functions and provide services to us (“Service Providers”) we engage trusted third party providers. The suppliers with which FENG shares User personal data vary depending on a number of factors, such as which of our App, website and services, a User engages with. For example, to provide our services to Users, we usually use the following suppliers:

• Authentication services – to allow customers to authenticate their account (for example, Facebook)
• Billing services – to allow customers to purchase paid features of our App (for example, Google Play)
• Product improvement and market research – we use third party platforms and agencies to carry out customer surveys and market research to improve our products and services

• Social media providers – to allow customers to create/connect their FENG account with their account(s) on such platforms (for example Facebook, Instagram or Spotify)
• IT services – some of the third-party software providers used in the operation of our business may process Users’ personal data (for example, if a User contacts us via social media with a support inquiry, their inquiry is processed by our customer support team

Due diligence is carried out on all Service Providers we engage to ensure they have in place adequate data protection and information security measures and only provide them with the personal data necessary to the service they are providing. Our suppliers are also subject to extensive obligations under our contractual arrangements, including strict data retention limits and measures are taken to ensure that the data shared is non-attributable to the greatest extent possible.

Marketing Services Providers – Sharing your personal data

To help us market and advertise our App and services on third party websites and applications and measure the effectiveness of our advertising campaigns we partner with providers of marketing services (‘Marketing Services Providers’) (Such as Facebook for example. For reasons such as:

• if you already have a FENG account; to exclude you from advertising campaigns aimed at finding new users,
• to show FENG adverts to existing Users to encourage them to use the service (for example, when we release new features for the App, we may advertise these features to existing users);
• to show FENG adverts to users who have visited the FENG App/Sites but haven’t yet created a FENG account;
• to include you in a ‘custom audience’ that will receive FENG advertising content (a custom audience is essentially a list of people who we think are most likely to be interested in a particular advertisement).
• to create an audience for our advertisements of other potential users who have similar characteristics to you based on the information the Marketing Service Providers holds about you (also known as a Lookalike Audience);

We share a limited amount of your personal data with these Marketing Services Providers, namely:

• the advertising identifier associated with your device (this is a random number assigned by your mobile device manufacturer (for example Google or Apple) to your device to help advertisers (including the manufacturer) know when an ad has been viewed or clicked in an app, and when an ad causes a ‘conversion’ (for example, downloading the app advertised to you))
• age and gender

your estimated location (based on your IP address)

• data about your visit to App, website, sites, and action taken on those (for example if you created an account with our App or downloaded our App)

For more information about how we tracking technologies such as cookies, including how you can set and manage your preferences with regards to such technologies, please see our Cookie Policy.

Before FENG is permitted some sites require user consent to use data gained via the platform for advertising purposes and where this is applicable, FENG will only use this data where the necessary consent has been collected. Via your device’s privacy settings, you have the option to limit or prevent device identifiers being shared with third party advertisers and what use is made of them.

In certain cases, these third parties will also use the data for their own purposes. For example they may merge your data with other data they hold and then use this to inform advertising related services provided to other clients.

Privacy laws applicable in your country may give you the following rights:

1. Right to be informed: what personal data an organization is processing and why (we provide this information to you in this Privacy Policy).
2. Right of access: you can request a copy of your data.
3. Right of rectification: if the data held is inaccurate, you have the right to have it corrected.
4. Right to erasure: you have the right to have your data deleted in certain circumstances.
5. Right to restrict processing: in limited circumstances, you have the right to request that processing is stopped but the data retained.
6. Right to data portability: you can request a copy of certain data in a machine-readable form that can be transferred to another provider.
7. Right to object: in certain circumstances (including where data is processed on the basis of legitimate interests or for the purposes of marketing) you may object to that processing.
8. Rights related to automated decision-making including profiling: there are several rights in this area where processing carried out on a solely automated basis results in a decision which has legal or significant effects for the individual. In these circumstances your rights include the right to ensure that there is human intervention in the decision-making process.

If you want to exercise any of your rights listed above please email our Data Protection Officer at hello@feng-app.io. You can also contact us by post at the following address: 85, Great Portland Street, London, W1W 7LT, United Kingdom. For your protection and the protection of all of our Users, we may need to request specific information from you to help us confirm your identity in order to answer the above requests.

If you have a concern over how we have processed your request or your personal data, you should contact us in the first instance via the contact details listed above.

If you feel we have not resolved your concern, you have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk).

We would love as many people as possible to enjoy our fashion creation, but you have to be at least 18 years old to use FENG. Please come back when you’re old enough!

FENG does not collect any information knowingly about children, nor market to minors, children, or anyone under the age of 18. We request that you do not submit information to us if you are under 18. If we become aware that a minor, child or anyone under the age of 18 has registered with us and provided us with personal information, we will take steps to terminate that person’s registration and delete their Registration Information from FENG. If we do delete a profile because you violated our ‘no children’ rules, we may keep your email and IP address to ensure that you do not try to create a new profile.

We pride ourselves at FENG on taking all appropriate security measures to help protect your information against misuse, loss and unauthorized disclosure or access. We use reasonable security measures to safeguard the confidentiality of your personal information such as secured servers using firewalls.

However, no website or Internet transmission is ever completely 100% secure and even we cannot guarantee that hacking, unauthorized access, data loss or other breaches wont ever occur, however we do have tips to hand in order to help keep your data secure:

1. Please don’t share the password you use to access your FENG Account with anyone else!
2. Please make sure you log out of your Account after use as you never know who may stumble onto your Account!
3. Change your password periodically.

We cannot guarantee the security of your personal data while it is being transmitted to our site and any transmission is at your own risk. If you ever think someone has had access to your Account 0r Password, please contact the team at Hello@feng-app.io.

Using your social media details to sign in to FENG

When you sign in to our App using your Facebook account, you give permission to Facebook to share with us your name and profile picture. Unless you opt-out, you also give permission to Facebook to share with us your email address (if there is one associated with your Facebook account), date of birth, profile photos, gender, Page likes and current town/city.

If you register or sign in with your Apple ID, you give Apple permission to share your Apple login, a name (that can be edited by you) and an email (you can choose to hide your email and Apple will create a random email address so your personal email can stay private). This email address will be linked to your FENG account and will be used to retrieve your FENG account.

We will then use this personal data to form your FENG account. If you remove the FENG app from your Facebook settings, or from your Apple ID, we will no longer have access to this data. However, we will still have the personal data that we received when you first set up your FENG account using your Facebook or Apple ID (you must delete your FENG account entirely for us to no longer have access to this data).

Linking social media accounts to your FENG account

You may link your FENG account with your Instagram, Facebook or Spotify accounts. This allows you to share some information from those accounts directly to your FENG account (for example, Instagram photos, or your top Spotify artists).

The information we receive is limited as Instagram, Facebook and Spotify permit to be transferred (as detailed by Instagram/Facebook/Spotify and agreed by you when you first connect your account from such platforms with your FENG account).

If you change your mind and no longer wish to link your FENG account to your Instagram, Facebook or Spotify account, please visit the settings in your Instagram, Facebook or Spotify account and follow the instructions to remove the FENG app access permissions. Please note though that any information already added to your FENG account from those platforms will not be deleted unless you delete it within your FENG account too.

The hardware is located in third-party data centres. Data collected by Advertising Partners and other Service Providers may also be held outside the UK and the European Economic Area. We ensure that the data is adequately protected by ensuring that legal, valid mechanisms are in place such as: EU approved model clauses and implementing robust contractual standards. If you want more information relating the safeguards we have in place, please email hello@feng-app.io.

Your personal information is only kept for as long as we need it for the legal basis relied upon (as set out in Section 2 above) and as permitted by applicable law.

You may permanently delete your FENG Account at any time (although we would be very upset to see you go!)

Once your Account is deactivated, we take reasonable efforts to make sure it is no longer viewable on the App. We must keep it to comply with applicable law (for instance, if you make purchases within the App, some personal data may need to be kept for accounting purposes);

1. we must keep it to evidence our compliance with applicable law;
2. there is an outstanding claim, issue or dispute requiring us to keep the relevant information until it is resolved; or
3. the information must be kept for our legitimate business interests, such as enhancing Users’ safety and security as fraud prevention. For example, information may need to be kept security incidents from opening a new account or to prevent a user who was banned for unsafe behaviour.

4. Where FENG uses machine learning, for example, to help both detect and prevent fraudulent card transactions, and to detect and prevent spam communications on the FENG App (as aforementioned above), we may need to keep personal information for a longer period than the retention periods set out, to enable the machine learning to work properly. In this case, we always seek to minimize the amount of personal information that is used and ensure that it is ring-fenced and kept securely from another User’s personal information. We regularly review the period for which personal information is required for machine learning purposes and delete any identifiable information when it is no longer required.

To prevent misuse and/or abuse of FENG by a User following deletion or termination of a profile/Account we shall retain such information as we deem in our sole discretion may be necessary to ensure that User does not open a new Account and profile in breach of our Terms and Conditions and to ensure compliance with all regulations and laws.

WARNING: Even after you delete your Account or remove information from your personal profile, copies of that information may still accessed or viewable to the extent such information has been previously shared with others or stored or copied by others. We do we accept any liability for this as we cannot control this. If you have given third party websites or applications access to your personal information, they may retain such information to the extent permitted under their privacy policies or terms of service.

As FENG evolves, we may revise and update this Privacy Policy from time to time. The most current version of the policy will govern our use of your information and will always be at FENG-app.io/privacy. If we make a change to this policy that, in our sole discretion, is material, we will notify you, for example, by posting a notice within FENG or via an email to the email associated with your Account.